qauery_ E Invoicing

[UMESH KUMAR]

Whether a registered person supplying nil rated goods raising bill of supply is required to raise e-invoice

[Shilpi Jain]

e-invoicing not required for bill of supply.

[ABHISHEK TRIPATHI]

Dear Umesh Ji,

In addition:

FAQ No. 11. Is e-invoicing applicable for NIL-rated or wholly-exempt supplies?

No. In those cases, a bill of supply is issued and not a tax invoice.

[UMESH KUMAR]

I am of the same view and FAQ supports that, but is there any specific notification regarding nonapplicability of e invoicing when Bill of Supply is issued

[ABHISHEK TRIPATHI]

Dear Umesh Ji,

E-invoice is nothing but an invoice. For the purpose of e-invoice, changes are made in Rule 48 (Manner of issuing invoice). So, one may construe that e-invoice is just a manner of issuing an invoice, and the original concept of invoicing stand stiff. This means, if one needs to issue an invoice then follows the manner of issuing an e-invoice.

In short, e-invoicing is only in the cases of invoicing [Refer Rule 46. 47 and 48]. The legal concept is of invoice and the format/manner of issuing such invoice is ‘e-invoice'. That is why in bill of supply cases you cannot issue ‘e-invoice'. It’s like can one issue invoice in case of bill of supply, the answer is obviously ‘no’.

[KASTURI SETHI]

Sh.Umesh Kumar Ji,

Q. Is there any specific notification regarding non-applicability of e invoicing when Bill of Supply is issued ?

Ans. No. In the absence of specific notification, FAQ would suffice.

[NISHANT SHAH]

As per FAQ, e-invoicing apply to,

1)Supplies to registered persons (i.e., B2B supplies)

2)Supplies to SEZ with/without payment of tax

3)Exports with/without payment of tax &

4)Deemed exports

[ABHISHEK TRIPATHI]

We don;t need any notification for that.

E-invoice means electronic invoice means it is still an invoice but electronic. Characteristic remains the same, only format changes.

In future for bill of supply, it will be, 'e - bill of supply'

[DR.MARIAPPAN GOVINDARAJAN]

I endorse the views of Shri Abishek.

AI Summary

E-invoicing not applicable to bills of supply; electronic invoicing applies only where a tax invoice is issued.
E-invoicing is confined to transactions requiring a tax invoice and does not apply to bills of supply issued for nil-rated or wholly exempt supplies; the FAQ states e-invoicing is not applicable where a bill of supply is issued. E-invoicing applies to B2B supplies, supplies to SEZs, exports, and deemed exports. Invoicing rules prescribe the manner of issuing invoices, and absent specific notification, the FAQ guidance on non-applicability to bills of supply is relied upon.